House of S.P. Capital Financing Ltd. - is a Non Banking Finance Company registered with Reserve Bank
of India as Non Banking Finance Company.

Business Process

Strong Business Processes lead to a more efficacious system of governance. The management shall, within its overall
corporate plan.....

Business Ethics

SPC is committed to seeking long term success with no compromise on ethical business standards. The highest standards
of integrity.....

Employees

SPC recognizes that the success of its operations is dependent to a large extent on the commitment and support of its
workforce.....

Code of Conduct for Senior Management and Employees

Introduction

The past decade has seen several exciting changes in India’s economic thinking. The liberalized business and legal
environment, privatization of the public sector, the globalization of the economy and the resulting freedom and challenges
have resulted in a dramatic growth in business and business opportunities, and in the way business is conducted. In this
environment, it is imperative to maintain the highest standards of corporate conduct and business principles; we should be
concerned not just with maximizing profits and shareholder value, but be equally conscious of responsibilities to each of
the stakeholders – employees, business associates and partners, financiers, society and the state.

Corporate Governance Policies

Good corporate governance begins with a Company’s own internal practices and policies. While corporate governance issues
are common across organizations, each Company requires governance principles that are unique in their approach.

Our Products and Services

Our product and services shall be technologically competitive and whilst fulfilling the needs of our customers, shall
offer the best possible value to the customer. They shall be cited for the purpose for which they are merchandised,
and shall be recognized for their quality.....

Legal Compliances

We shall conduct our businesses as a responsible corporate citizen and shall follow the applicable legal framework of the
country in which we operate by the letter of the law and in spirit. SPC expects all its employees to function in line with
this principle.....

Competition

SPC believes that for business to be successful, competition has to be vigorous,free and fair.We shall compete through the
inherent quality and excellence of our products and services, never through illegal, unethical or unfair business practices.....

Business Partner and Joint Venture

A proper choice of business partners is vital for the success of the Company and of the S.P.C companies.

Associations shall be encouraged, in India or abroad, with such entities as are able to add value to the Company’s products
or services, or help fulfill the strategic growth plans of the Company.

Only such persons shall be selected to be our business partners where there is a complete match in the partner’s.....

Record Keeping

Accounting and other records will be maintained in keeping with the highest standards of excellence and transparency.
The highest level of integrity is expected of those to whom are entrusted the responsibility of maintaining the books of
account and other records of the Company.

In recording transactions in the books of account of the Company, no attempts shall be made to disguise the true nature of
the transactions being recorded. Records shall be maintained in accordance with all applicable laws and regulations.

Political and Trade Affliations

SPC neither supports any specific political party nor it has any particular political affiliations. Accordingly,
therefore no contribution.....

Investor Relations

Our Investor Relations shall be ethical, professional, transparent and investor friendly.We recognize the right of our
Investors to information.....

Compliance Monitoring and Reporting

The success of this Code lies in its implementation and periodic review. The Corporate Governance Cell and the Board of
Directors of the Company.....